SMS and the EASA rules Effective management systems for ... · PDF fileEffective management...
Transcript of SMS and the EASA rules Effective management systems for ... · PDF fileEffective management...
AESA SMS/SSP Conference Madrid, 10 & 11 May 2012
SMS and the EASA rules
Effective management systems for
authorities and organisations
Régine Hamelijnck
Rulemaking Directorate Product Safety Department
Outline
01 – Current “state of play”
02 – Authority and Organisation Requirements
Authority and Organisation RequirementsMay 2012 2
Outline
01 – Current “state of play”
02 – Authority and Organisation Requirements
Authority and Organisation RequirementsMay 2012 3
Outline
01 – Current “state of play”
02 – Authority and Organisation Requirements
Authority and Organisation RequirementsMay 2012 4
Basic Regulation
Airworthiness
Regulation
Initial airworthiness
Regulation
Continuing airworthiness
Flight Standards
Regulation
Aircrew
Regulation
Air operations
Regulation
TCO
ATM/ANS
Regulation
ATCO
Regulation
SERA
Regulation
AUR
Regulation
ATM/ANS
Systems
Aerodromes
Regulation
ADR
Rule structure – the big picture
Authority and Organisation RequirementsMay 2012 5
Basic Regulation
Airworthiness
Regulation
Initial airworthiness
Regulation
Continuing airworthiness
Flight Standards
Regulation
Aircrew
Regulation
Air operations
Regulation
TCO
ATM/ANS
Regulation
ATCO
Regulation
SERA
Regulation
AUR
Regulation
ATM/ANS
Systems
Aerodromes
Regulation
ADR
Rule structure – the big picture
ADR: Aerodromes
ATCO: licensing and medical certification of air traffic controllers
AUR: common airspace usage requirements and operating procedures
SERA: Standardised European Rules of the Air
Airworthiness
(initial Agency remit)
Authority and Organisation RequirementsMay 2012 6
Airworthiness
Regulation 1702/2003 - Initial Airworthiness
• Scope:
• Design
• TC, restricted TC, changes to TC and restricted TC, STC
• Design Organisation Approval
• Manufacture
• Production Organisation Approval (POA)
• Production without POA
• EASA is the competent authority for:
• Product Certification,
• DOA,
• third country POA and single POA (Airbus)
Authority and Organisation RequirementsMay 2012 7
Airworthiness
Regulation 1702/2003 - Initial Airworthiness
• SMS not yet implemented
• Will be introduced through Rulemaking Task MDM.060, which has just started
• SMS elements will be based on those developed for Flight Standards
• Proposed that all POAs as well as all DOAs implement a management system encompassing SMS (not only those designing/manufacturing aircraft, engines or propellers)
• NPA: end 2012/ beginning 2013
• Opinion/Decision: 1st Quarter 2014 (Regulation one year later)
Authority and Organisation RequirementsMay 2012 8
Airworthiness
Regulation 2042/2003 - Continuing Airworthiness
• Scope:
• Maintenance (Part-145 / Part-M Subpart F)
• Continuing Airworthiness Management (“Part-M Subpart G”)
• Maintenance Training (Part-147)
• Aircraft Mechanics Licensing (Part-66)
• EASA is the competent authority for:
• third country organisations (Maintenance, Maintenance Training and Continuing Airworthiness Management Organisations)
• SMS not yet implemented
• Will be introduced through rulemaking Task MDM.055 (ToRs published 07/2011)
• SMS elements will be based on those developed for Flight Standards
• NPA: September 2012
• Opinion/Decision: 2nd Quarter 2013 (Regulation one year later)
Authority and Organisation RequirementsMay 2012 9
Basic Regulation
Airworthiness
Regulation
Initial airworthiness
Regulation
Continuing airworthiness
Flight Standards
Regulation
Aircrew
Regulation
Air operations
Regulation
TCO
ATM/ANS
Regulation
ATCO
Regulation
SERA
Regulation
AUR
Regulation
ATM/ANS
Systems
Aerodromes
Regulation
ADR
Rule structure – the big picture
“FIRST EXTENSION”
first opportunity for EASA to
develop “SMS” rules
Authority and Organisation RequirementsMay 2012 10
History EASA rulemaking in the area of SMS
EASA Rulemaking tasks: OPS.001 & FCL.001 – started in July 2006
•extend scope of EASA regulations to “flight crew licensing” and “air operations”, while implementing the relevant ICAO Standards on SMS
Proposal for Part “Authority Requirements” (AR) and Part “Organisation Requirements” (OR)
•NPA 2008-22 published in October 2008
•NPA 2009-02 published in January 2009
Opinion 03/2011 published in April 2011
•Part-ARA and Part-ORA for aircrew (Flight Crew & Cabin Crew)
•Regulation (EU) 290/2012 published in April 2012
•AMCs and GM recently published (see Decisions 2012/006/R and 2012/007/R)
Opinion 04/2011 published in June 2011
•Part-ARO, Part-ORO and technical requirements for air operations (Commercial Air Transport)
•Passed EASA Committee – Regulation expected 2nd semester 2012
See: http://easa.europa.eu/agency-measures/opinions.php
Authority and Organisation RequirementsMay 2012 11
Basic Regulation
Regulation
Aircrew
Annex I
Part-FCL
Annex IIConversion of national licences
Annex III Licences of non-EU states
Annex IV
Part-MED
Annex V
Part-CC
Annex VI
Part-ARA
Annex VII
Part-ORA
Rule structure – Aircrew
Authority and Organisation RequirementsMay 2012 12
Regulation 1178/2011 Regulation 290/2012
Flight Standards: Aircrew
Regulation 1178/2011 – “Civil Aviation Aircrew” initially covered Part-FCL, conversion of licences, non-EU licences and Part-MED
• amending Commission Regulation (EU) 290/2012 of 30 March 2012
• Annex V: Part-CC “Cabin Crew”
• Annex VI: Part-ARA “Authority Requirements for Aircrew”
• Annex VII: Part-ORA “Organisation Requirements for Aircrew”
SMS is addressed in Part-ORA
Authority and Organisation RequirementsMay 2012 13
Flight Standards: Aircrew
The following organisations will be required to implement a management system to comply with Part-ORA (SMS):
• Approved Training Organisations (ATOs)
• All organisations providing pilot training for ATPL, CPL, PPL, LAPL, BPL, SPL (= all professional and private pilot licences)
• Holders of an FSTD qualification certificate
• Aero-medical Centres (AeMCs)
EASA is the competent authority for:
• foreign ATOs, foreign AeMCs
• FSTDs located outside the territory of the EASA States
• FSTDs located within EASA States when the organisation operating them is established in a third country.
Authority and Organisation RequirementsMay 2012 14
Basic Regulation
Regulation
Air Operations
Annex I
DEF
Annex IIPart-ARO
Annex III Part-ORO
Annex IV
Part-CAT
Annex V
Part-SPA
Annex VI
Part-NCC
Annex VII
Part-NCO
Annex VIII
Part-SPO
Rule structure: Air Operations
CAT: Commercial Air Transport
SPA: Specific Approvals (e.g. PBN, LVO, ETOPS
NCC: Non-commercial OPS with CMPA
NCO: Non commercial OPS with other than CMPA
SPO: Specialised Operations (Aerial Work)
Authority and Organisation RequirementsMay 2012 15
“OPS I” package
Flight Standards: Air Operations
Draft EU Regulation on Air Operations, will supersede currentlyapplicable EU-OPS and national rules based on JAR-OPS 1 and 3
• First regulation will only cover Commercial Air Transport with aeroplanes and helicopters – publication expected second Semester 2012:
• Annex I: Definitions
• Annex II Part-ARO “Authority Requirements for Air Operations”
• Annex III Part-ORO “Organisation Requirements for Air Operations”
• Annex IV Part-CAT “Commercial Air Transport” - technical rules
• Annex V Part-SPA “Specific Approvals”
• Part-ORO will include management system requirements
SMS elements will be in Part-ORO
Authority and Organisation RequirementsMay 2012 16
Basic Regulation
Regulation
Air Operations
Annex I
DEF
Annex IIPart-ARO
Annex III Part-ORO
Annex IV
Part-CAT
Annex V
Part-SPA
Air operations: OPS I (Opinion 04/2011)
Scope: Commercial Air Transport with aeroplanes and helicopters
excluded: “A to A” flights:
CAT operations starting and ending at the same aerodrome/operating site with
Performance class B aeroplanes or non-complex helicopters
Authority and Organisation RequirementsMay 2012 17
Flight Standards: Air Operations
In the future, the Regulation will be amended to also cover:
• Commercial Air Transport (CAT) with sailplanes and balloons
• CAT A to A flights
• Non-Commercial operators of complex-motor-powered aircraft: Part-NCC, so called “Business Aviation”
• Non-Commercial operators of other-than complex-motor-powered aircraft: Part-NCO
• Aerial Work operators - commercial and non-commercial: Part-SPO “Specialised Operations”
• Rules concerning flight time limitations: FTL
Authority and Organisation RequirementsMay 2012 18
Air Operations – OPS I: transition
General “Opt-Out” provision:
• Member States may decide not to apply the provisions of Annexes I to V until up to two years after the entry into force of the Regulation.
• Entry into force: third day following publication in the EU Official Journal (date tbd).
Authority and Organisation RequirementsMay 2012 19
Air Operations – OPS I: transition
Grandfathering of existing AOCs
• applies to AOCs issued in accordance with Regulation (EC) No 3922/1991 as last amended (EU-OPS)
• applies to AOCs of aeroplane operators only
• AOC holders shall adapt their management system (SM), trainingprogrammes, procedures and manuals to be compliant with the new rulesno later than two years after the entry into force of the Regulation
• AOC holders shall begin to adapt their management system (SM), trainingprogrammes, procedures and manuals to be compliant with the new rulesfrom the date of entry into force!
Authority and Organisation RequirementsMay 2012 20
Air Operations – OPS I: transition
Existing AOCs - helicopter operators
• No automatic grandfathering due to varying degrees of compliance withJAR-OPS 3!
• AOCs shall be converted into AOCs compliant with the new Regulation inaccordance with a conversion report established by the Member Statethat issued the AOC, in consultation with the Agency.
• The conversion report will also need to describe how the operator willcomply with new management system provisions (SM).
• Conversion process must be completed by the end of the opt-outperiod chosen by the Member State issuing the AOC.
Authority and Organisation RequirementsMay 2012 21
Air Operations – Third Country Operators
Current status: CRD
• Comment Response Document (CRD) 2011-05 on ImplementingRules on Third Country Operators (TCO) published in January2012.
•Scope:
• Technical rules for TCOs performing commercial air transportoperations (CAT) into, within or out of the EU (Part-TCO),
• rules for the initial authorisation, continuous oversight and thefollow-up of findings (Part-ART) for those TCOs
• all relevant developments related to the Authorisation of TCOs are published here: TCO - Latest news.
Authority and Organisation RequirementsMay 2012 22
Outline
01 – Current “state of play”
02 – Authority and Organisation Requirements
Authority and Organisation RequirementsMay 2012 23
Outline
01 – Current “state of play”
02 – Authority Requirements
Authority and Organisation RequirementsMay 2012 24
Authority Requirements (ARs)
• To “regulate” in the area of Safety Management we need to
“regulate” both authorities and organisations.
• ARs support the European Aviation Safety Programme (EASP)
and SSP/SMS, in particular by focussing on specific ICAO
critical elements of an oversight system:
CE-3: State civil aviation system and safety oversight functions
CE-4: Technical personnel qualification and training
CE-5: Technical guidance, tools and the provision of safety-critical
information
CE-6: Licensing, certification, authorisation and/or approval obligations
CE-7: Surveillance obligations
CE-8: Resolution of safety concerns.
Authority and Organisation RequirementsMay 2012 26
Authority Requirements (ARs)
ARs establish requirements for:
the administration and management system to befulfilled by the Agency and Member States for theimplementation and enforcement of Regulation (EC) No216/2008 and its Implementing Rules.
ARs:include new provisions addressed to Member States toensure proper oversight capabilities.
support the implementation of EASP/SSP withoutexplicitly regulating SSP (refer to Communication fromthe EC, the Council and the EU Parliament Com(2011)670).
Authority and Organisation RequirementsMay 2012 27
Authority Requirements OPS
Part-ARO
Air Operations
Subpart GEN: General
Requirements
Section II: Management System
Authority and Organisation RequirementsMay 2012 28
Authority Requirements OPS (the same apply for aircrew)
AR0.GEN.200 Management system (extract)
Competent authorities shall implement a management system,including as a minimum:
(a) documented policies and procedures,
(b) sufficient number of personnel, qualified to perform their tasks,
(c) a system to plan the availability of personnel,
(d) adequate facilities and office accommodation to perform the allocated tasks,
(e) a function to monitor compliance including:
� internal audit process
� safety risk management process.
(f) procedures for participation in a mutual exchange of all necessary information and assistance with other competent authorities
…..
…..Authority and Organisation RequirementsMay 2012 29
Outline
01 – Current “state of play”
02 –Organisation Requirements
Authority and Organisation RequirementsMay 2012 30
Organisation Requirements & SMS
May 12 Authority and Organisation Requirements
EASA Organisation Requirements (ORs)developed for Flight Standards (Aircrew and AirOperations) mandate the implementation of a“management system” with specific features.
These requirements (IRs) and related AMCs/GMset out what is needed in terms of theorganisation’s management system.
These, together with the relevant provisions ofthe Basic Regulation (Regulation 216/2008) fullycover the existing ICAO Annex 1 and Annex 6SMS Standards.
31
Organisation Requirements - SMSEASA approach – main features
Total system approach
Integrated approach
Proportionality
Flexibility
Authority and Organisation Requirements
Authority and Organisation RequirementsMay 2012 32
Organisation Requirements OPS
Part-ORO
Air Operations
Subpart GEN: General
Requirements
Section II: Management System
Authority and Organisation RequirementsMay 2012 34
Part-ORO Subpart GENSection II “Management System”
Paragraph Title
ORO.GEN.200 Management system
ORO.GEN.205 Contracted activities
ORO.GEN.210 Personnel requirements
ORO.GEN.215 Facility requirements
ORO.GEN.220 Record-keeping
Authority and Organisation RequirementsMay 2012 35
Part-ORO Subpart GENSection II “Management System”
Paragraph Title
ORO.GEN.200 Management system
ORO.GEN.205 Contracted activities
ORO.GEN.210 Personnel requirements
ORO.GEN.215 Facility requirements
ORO.GEN.220 Record-keeping See explanatory note to Part-ORA:
Decision (2012/007/R)
Safety Management Requirements for
organisations - Correspondence
between ICAO SMS and Part-ORO &
Basic Regulation (Essential
requirements)
Authority and Organisation RequirementsMay 2012 36
(a) An operator shall establish, implement and maintain a managementsystem that includes:
(1) clearly defined lines of responsibility and accountability throughout theorganisation, including a direct safety accountability of the accountablemanager;
(2) a description of the overall philosophies and principles of the organisationwith regard to safety, referred to as the safety policy;
(3) the identification of aviation safety hazards entailed by the activitiesof the organisation, their evaluation and the management ofassociated risks, including taking effective actions to mitigate therisk;
(4) maintaining personnel trained and competent to perform their tasks;
(5) documentation of all management system key processes, including aprocess for making personnel aware of their responsibilities, and itsamendment procedure;
(6) a function to monitor compliance of the organisation with the relevantrequirements. Compliance monitoring shall include a feedback system offindings to the accountable manager to ensure effectiveimplementation of corrective actions as necessary.
Management System most relevant IR: ORO.GEN.200 (extract)
Authority and Organisation RequirementsMay 2012 37
AMCs and GM to ORO.GEN.200
Reference Applies to Subject
AMC1-
ORO.GEN.200(a)(1)(2)(3)(5)non-complex
- Responsibility and accountability
- Safety policy
- Hazard identification, risk management
- Documentation of management system key
processes
- Safety manager
- Emergency response plan
AMC1-ORO.GEN.200(a)(1) complex
Organisation and accountabilities:
- Safety manager
- Safety review board (SRB)
GM1-ORO.GEN.200(a)(1) complex Safety action group (SAG)
AMC1-ORO.GEN.200(a)(2) complex Safety policy and management commitment
GM1-ORO.GEN.200(a)(2) all Definition of safety policy
AMC1-ORO.GEN.200(a)(3) complex
Safety risk management:
- Risk management
- Management of change
- Continuous improvement
- Emergency response plan
Authority and Organisation RequirementsMay 2012 38
AMCs and GM to ORO.GEN.200
Reference Applies to Subject
GM1-ORO.GEN.200(a)(3) all Internal occurrence reporting scheme
AMC1 -ORO.GEN.200(a)(4) all Training and communication on safety
AMC1-ORO.GEN.200(a)(5) all Organisation management system documentation
GM1-ORO.GEN.200(a)(5) all Organisation management system documentation
AMC1-ORO.GEN.200(a)(5) complexOrganisation management system documentation –Safety management manual (SMM)
AMC1-ORO.GEN.200(a)(6) all
Compliance monitoring - general- Designation of a compliance monitoring manager - Compliance monitoring documentation - Training
AMC2-ORO.GEN.200(a)(6) non-complex Compliance monitoring - audit checklist
GM1.ORO.GEN.200(a)(6) complex Compliance monitoring - typical subjects
AMC1-ORO.GEN.200(b) all Size, nature and complexity of the activity
Authority and Organisation RequirementsMay 2012 39
SAFETY POLICY
The safety policy is the means whereby theorganisation states its intention to maintain and,where practicable, improve safety levels in all itsactivities and to minimise its contribution to the riskof an aircraft accident as far as is reasonablypracticable.
GM1-ORO.GEN.200(a)(2)
Authority and Organisation RequirementsMay 2012 40
SAFETY POLICY (endorsed by the accountable manager)
• establish safety objectives and performance standards
• reflect organisational commitments regarding safety and itsproactive and systematic management;
• enforce safety as one primary responsibility of all managers
• to be communicated throughout the organisation
• senior management should continually promote the safety policy to all personneland demonstrate their commitment to it
• should include safety reporting principles
• commitment not to blame someone for reporting something which would not havebeen detected otherwise.
AMC1-ORO.GEN.200(a)(2)
Authority and Organisation RequirementsMay 2012 41
Organisational set-up
AMC1-ORO.GEN.200(a)(1) AMC1-ORO.GEN.200(a)(6)
Accountable Manager (AM)
Safety Manager
(SM)
Compliance Monitoring Manager (CMM)
Safety Review Board (SRB)
Accountable Manager plus Heads of functional areas
Safety Action Group (SAG)
Authority and Organisation RequirementsMay 2012 42
Functions :1. facilitate & coordinate hazard identification, risk analysis
and management;
2. monitor the implementation of actions taken to mitigaterisks, as listed in the safety action plan;
3. provide periodic reports on safety performance;
4. ensure maintenance of safety managementdocumentation;
5. ensure that there is safety management training availableand that it meets acceptable standards;
6. provide advice on safety matters; and
7. initiate and participate in internal occurrence / accidentinvestigations.
Safety Manager AMC1-ORO.GEN.200(a)(1)
Authority and Organisation RequirementsMay 2012 43
• high level committee, chaired by the AM.
• considers matters of strategic safety.
FUNCTIONS:
1. monitor safety performance against the safety policy and objectives;
2. ensure safety actions are taken in a timely manner;
3. ensure the organisation’s safety management processes remain effective.
Safety Review BoardAMC1-ORO.GEN.200(a)(1)
Authority and Organisation RequirementsMay 2012 44
optional
• May be established as a standing group or as an ad-hoc group toassist or act on behalf of the Safety Review Board.
• More than one safety action group may be established dependingon the scope of the task and specific expertise required.
• A safety action group should report to and take strategic directionfrom the Safety Review Board and should be comprised ofmanagers, supervisors and personnel from operational areas.
e.g. to assess impact on safety of operational changes, such as:
introduction of a new type of aircraft
use of a new contractor
implementation of new software for component tracking
Safety Action GroupGM1-OR.GEN.200(a)(1)
Authority and Organisation RequirementsMay 2012 45
• Hazard identification processes
• reactive & proactive
• Risk assessment and mitigation processes
• analysis, assessment and control of risks
• Internal safety investigation following occurrences
• Not limited to occurrences required to be reported
• Safety performance monitoring and measurement
• Combination of safety reporting, safety studies, safety reviews,safety audits, safety surveys.
• Management of change
• Identify changes that may adversely affect safety
• Use existing tools and mechanisms to assess and manage relatedrisks
SAFETY RISK MANAGEMENT AMC1-ORO.GEN.200(a)(3)
Authority and Organisation RequirementsMay 2012 46
• Continuous improvement
• reactive and proactive evaluation of facilities, equipment,documentation, procedures (audits and surveys)
• Evaluation of individual’s performance in terms of safetyresponsibilities
• Reactive evaluation of effectiveness of risk controls
• Emergency Response Plan
• Actions to be taken in case of an emergency
• Ensure orderly and safe transition from normal to emergencyoperation
• Need to co-ordinate with ERPs of other organisations whereappropriate
SAFETY RISK MANAGEMENT AMC1-ORO.GEN.200(a)(3) - continued
Authority and Organisation RequirementsMay 2012 47
• one important element of the hazard identification process, improve the safety performance without attributing blame
• to identify instances where routine procedures have failed
• assessment of safety implications to determine need for action
• dissemination of relevant safety information stemming fromincidents and accidents
• allows reactive evaluation of effectiveness of risk controls
GM1-ORO.GEN.200(a)(3)
Internal Occurrence Reporting scheme
Authority and Organisation RequirementsMay 2012 48
TRAINING AND COMMUNICATION ON SAFETY
• All personnel to receive safety training as relevant to their responsibilities
• Communication on safety matters:
• Raise awareness on safety management activities.
• Convey safety critical information on risks identified.
• Explain why actions are taken, why procedures are introducedor changed.
AMC1-ORO.GEN.200(a)(4)
Authority and Organisation RequirementsMay 2012 49
ORGANISATION MANAGEMENT SYSTEM DOCUMENTATION• General items to be covered (minimum required for all organisations)
• Statement by the accountable manager “organisation will continuouslywork in accordance with the applicable requirements and theorganisation’s documentation”
• Scope of activities
• Names of nominated post holders
• Organisation chart with lines of responsibility
• Procedures specifying how compliance with requirements is ensured(auditing)
• Management system documentation amendment procedure
AMC1-ORO.GEN.200(a)(5)
Organisations may
adopt any title for this
document
Authority and Organisation RequirementsMay 2012 50
SAFETY MANAGEMENT MANUAL
key instrument for communicating the approach to safety for thewhole of the organisation, to document all aspects of safetymanagement:
1. scope of safety management
2. safety policy and objectives
3. safety accountability of the accountable manager
4. safety responsibilities of key safety personnel
5. hazard identification and risk management schemes
6. safety action planning
7. safety performance monitoring
8. incident investigation and reporting
9. emergency response planning
10. management of change
11. safety promotion
AMC1-ORO.GEN.200(a)(5)
Authority and Organisation RequirementsMay 2012 51
ORGANISATION MANAGEMENT SYSTEM DOCUMENTATION
The information may be contained in any of the organisation manuals
• safety management manual,
• operations manual,
• training manual
• …
These manuals may also be combined, e.g. the SMM can be one chapter of the operations manual or the operations manual can be integrated with the SMM.
GM1-ORO.GEN.200(a)(5)
It is not required to duplicate
information in several manuals,
however the organisation must
be able to demonstrate that all
items are covered
Authority and Organisation RequirementsMay 2012 52
Additional requirements are defined in the Subparts:
DOCUMENTATION – OPS
ORO.MLR – Manuals, Logs and Records
• ORO.MLR.100 Operations manual – General & related AMCs
• ORO.MLR.101 Operations manual – Structure & related AMCs
Authority and Organisation RequirementsMay 2012 53
COMPLIANCE MONITORING FUNCTION Accountable manager to designate a compliance monitoring manager (CMM)
Functions of the CMM:
• verify that all applicable standards are complied with
• verify that the organisation’s own requirements (policies and procedures) are complied with
• ensure that a compliance monitoring programme is implemented and continually reviewed & improved
AMC1-ORO.GEN.200(a)(6)
Organisations may
adopt a different
title for this function
Authority and Organisation RequirementsMay 2012 54
COMPLIANCE MONITORING FUNCTION
Position of the CMM:
• direct access to the accountable manager
• not one of those nominated to be responsible for the operational areas (referred to in ORO.GEN.210(b))
• access to all parts of the organisation and as necessary, to contracted organisations
AMC1-ORO.GEN.200(a)(6)
The same person may act as CMM
and SM (under certain conditions)
Non-complex ORG:
AM can be the CMM
Authority and Organisation RequirementsMay 2012 55
COMPLIANCE MONITORING DOCUMENTATIONIntegrated with organisation’s management system documentation, to describe :
the allocation of CM duties and responsibilities (coordination & auditing)
procedures to monitor regulatory compliance
the compliance monitoring programme, reflecting
schedule of the monitoring programme;
audit procedures;
reporting procedures;
follow-up and corrective action procedures;
training on compliance monitoring;
recording system.
AMC1-ORO.GEN.200(a)(6)
No fixed audit planning
cycles – according to
size of the organisation
and its complexity –
dynamic planning
(performance based)
Authority and Organisation RequirementsMay 2012 56
Compliance monitoring shall also cover processes for the identificationof aviation safety hazards and management of associated risks.
� Are policies and procedures in place and adhered to?
� Are hazard identified, risks assessed and managed?
The verification of the effectiveness of the hazard identificationprocess and mitigation actions is within the remit of the safetymanagement function (safety manager – SRB – SAG)
� How effectively have risks been mitigated ?
� Has overall safety performance increased ?
Compliance Monitoring ./.
Safety Management
If the same person acts as SM
and CM, he/she cannot audit
any of the SM processes
Authority and Organisation RequirementsMay 2012 57
• ESSI – (ECAST – EGAST – EHEST)
see for example: advanced methodology for operational riskassessment http://easa.europa.eu/essi/documents/Methodology.pdf
• SKYBRARY http://www.skybrary.aero/index.php/Main_Page
see for example:
Operators Guide to Human Factors in Aviation (OGHFA)
• ICAO Doc. 9859 “Safety Management Manual”
Edition 3 is about to be released
Additional guidance material
Authority and Organisation RequirementsMay 2012 58
EASA Organisation Requirements & SMS KEY POINTS
SMS is addressed as part of “Organisation Requirements – Management System”
Organisation Requirements
• are compatible with existing management systems
• encourage integrated management
• provide proportionality (complex versus non-complex organisations)
• provide flexibility (details in AMC)
These Organisation Requirements set the standard for implementing SMS in the other areas within EASA’s remit.
Authority and Organisation RequirementsMay 2012 59
Future Rulemaking on SMS
Task MDM.094 Safety Management
“First review of Organisation and Authority Requirements”
� consider latest developments:� ICAO Annex 19
� new SMM
� Safety Management International Collaboration Group (SM-ICG)*deliverables
� provide further guidance material, e.g. :� management systems for small (“non-complex”) organisations
� safety risk management
� measuring safety performance
* ICG: promotes a common understanding of SMS and SSP principles and requirements,
strives to harmonise SMS efforts, collaborates on common topics of interest, shareslessons learned, and ensures the progression of a harmonised SMS.
Authority and Organisation RequirementsMay 2012 61